I think there's reason for concern based on the load that the commissioner is facing, realistically. We've had a situation for the last number of years with the Privacy Commissioner where findings sometimes run between 12 and 18 months because there simply haven't been the resources to deal with issues.
If this gets interpreted aggressively by organizations to say, “Well, it's impractical to obtain consent, so let's just run off and ask the commissioner”, I think there's a concern that there will be delays, which businesses aren't going to be happy with, but there's also the question of whether this is going to get the sort of study that's necessary.
I'd be curious to hear what some of my colleagues on the panel think.